Ethics Follow-up Report

Compass with the arrow pointing at Ethics, superimposed over the Denver skyline.


The 18 recommendations from the original audit report were directed to either the Board of Ethics or the Clerk and Recorder’s Office for implementation.

The Board of Ethics fully implemented six recommendations it agreed to in the original report, but five others have yet to be fully implemented or acted upon. The board also implemented a seventh recommendation, despite disagreeing to it in the original report.

The board developed and documented some policies and procedures to address certain risks, but it failed to implement others — such as a process for recusal that would dictate how recusals occur or a process that would detail how risks to the board’s operations are identified and mitigated. This may lead to inconsistency in board members’ recusal practices.

The board also failed to fully document its plan to strengthen its formal ethics training and outreach. Although the board created and implemented a process for formal training and informal training opportunities, its plan does not consider training for various management levels.

Meanwhile, the Clerk and Recorder’s Office fully implemented four recommendations made in the original audit report, but two others have yet to be fully implemented or acted upon.

To ensure the effectiveness of gift disclosure requirements, the party responsible for enforcing requirements should be clearly identified. We encourage the Clerk and Recorder’s Office to build upon the progress it made with the fully implemented recommendations. Residents should have confidence that officials disclose gifts appropriately and that an effective mechanism is in place to ensure long-term compliance.

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Auditor's Letter

December 2, 2021

In keeping with generally accepted government auditing standards and Auditor’s Office policy, as authorized by city ordinance, the Audit Services Division has a responsibility to monitor and follow up on audit recommendations to ensure city agencies address audit findings through appropriate corrective action and to aid us in planning future audits.

In our follow-up effort for the “Ethics” audit report issued in February 2020, we determined the Board of Ethics and the Clerk and Recorder’s Office fully implemented 10 of the 18 recommendations we made in the original audit report. Although the board initially disagreed with one of our recommendations, we found it did take action to mitigate the risk.

Despite the Board of Ethics’ and the Office of the Clerk and Recorder’s efforts, auditors determined some risks associated with the audit team’s initial findings have not been fully mitigated. As a result, the Audit Services Division may revisit these risk areas in future audits to ensure the city takes appropriate corrective action.

The Highlights page in this report provides background and summary information about the original audit and the completed follow-up effort. Following the Highlights page is a detailed implementation status update for each recommendation.

I would like to express our sincere appreciation to the personnel in the Board of Ethics and the Clerk and Recorder’s Office who assisted us throughout the audit and the follow-up process. For any questions, please feel free to contact me at 720-913-5000.

Denver Auditor,

Auditor's Signature
Timothy O'Brien, CPA



Denver Auditor

Denver Auditor´s Office

201 W. Colfax Ave. #705 Denver, CO 80202
Call: 720-913-5000
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